VPN99 understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site AND/OR You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

Account means an account required to access and/or use certain areas and features of Our Site.

Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.

GDPR means European Union’s (“EU”) 2016/679 General Data Protection Regulation which came into effect from 25 May 2018

We/Us/Our/Company/Data Controller/VPN99 means SMERTRIOS LIMITED, a limited company registered in Ifigeneias, 17, Strovolos, 2007, Nicosia, Cyprus.

User/You/Your/Customer means the data subject in according with the GDPR definitions.

Information About Us

Our Site, is owned and operated by VPN99, a limited company registered in Ifigeneias, 17, Strovolos, 2007, Nicosia, Cyprus

Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

What Data Do We Collect?

Some data will be collected automatically by Our Site. Depending upon your use of Our Site, We may collect some or all of the following data:

email address;
IP address (automatically collected);
web browser type and version (automatically collected);
operating system (automatically collected);

SMERTRIOS LIMITED doesn't collect and store credit card data.

How Do We Use Your Data?

All personal data is stored securely in accordance with the GDPR. We use your data to provide the best possible services to you. This includes:

Providing and managing your Account;
Providing and managing your access to Our Site;
Personalising and tailoring your experience on Our Site;
Supplying Our services to you;
Personalising and tailoring Our services for you;
Responding to communications from you;
Supplying you with email (you may unsubscribe or opt-out at any time by clicking ‘unsubscribe’ button within the mail);
Market research;
Analysing your use of Our Site and gathering feedback

Processing of your personal data is based on Article 6(1) lit. b GDPR because it’s necessary for the performance of a contract to which the data subject is party in according with Terms and Conditions of use.

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

you have given consent to the processing of your personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract
processing is necessary for compliance with a legal obligation to which we are subject
processing is necessary to protect the vital interests of you or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental ights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

How and Where Do We Store Your Data?

We only keep your data for as long as We need tools We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy

Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

SMERTRIOS LIMITED will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, it’s Acquirer, Visa/Mastercard Corporations or in response to valid government demands.

What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes

How Can You Control Your Data?

When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and by managing your Account.

Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict your internet browser’s use of Cookies.

You may withdraw your consent for Us to use your personal data at any time by contacting Us using the details set out in section, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.

How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected]. Alternatively, please refer to Our Data Protection Policy.

What Cookies Do We Use and What For?

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site. These Cookies are not integral to the functioning of Our Site.

All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

Before any Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

Certain features of Our Site depend on Cookies to function. EU Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Our Site uses analytics services provided by third-parties developers. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you. You may remove these Cookies and prevent future use of them by following the steps.

You can see all the cookies we’re using, choose to enable or disable Cookies and change or withdraw your consent at our Cookie declaration page or in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Summary of Your Rights under GDPR Under the GDPR, you have:

the right to request access to, deletion of or correction of, your personal data held by Us;
the right to complain to a supervisory authority;
be informed of what data processing is taking place;
the right to restrict processing;
the right to data portability;
object to processing of your personal data;
rights with respect to automated decision-making and profiling To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us. More information about your rights under GDPR you can see within GDPR Articles: 15, 16, 17, 18, 20, 21, 77. 1

Automated Decision-Making and Profiling

We do not use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You.

Data Protection Officer

If you have any questions about Our Site or this Privacy Policy, please contact our Data Protection Officer by email at [email protected]. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.